FOPARFriends of Parks and Recreation (Santa Cruz, California)
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FOPAR should first attempt to secure a foreign tax refund unilaterally with respect to the section 482 adjustment amount.
The taxpayer should investigate the foreign tax credit rules applicable to FOPAR to determine whether the foreign jurisdiction will allow a foreign tax credit to offset the U.
A current repatriation payment by FOPAR to USSUB should be treated as a nontaxable capital contribution.
An additional (and potentially disabling) complexity -- involvement of a third country -- is presented if FOPAR is in a different foreign tax jurisdiction from FOSIB.